April 2006 - Safety Awareness
posted by Larry J SmithSubmitted by: Larry J. Smith, P.E.
Introduction
That old slogan, “Safety is Everyone’s Job” makes us aware that everyone plays a role in preventing lost-time injuries. Construction Contractors are required to prepare an Activity Hazard Analysis for any activity presenting hazards to employees or subcontractors.
A recent article published by Dennis Sobota, P.E. (1.) raises the importance of “always being aware of your environment.” Mr. Sobota points out that the Corps of Engineers Safety and Health Requirements Manual EM-385-1-1 is a “perfect fit” for identifying and documenting hazards along with recommended controls to mitigate losses.
This Article features the new elements for safety management "Monthly Record of Work-Related Injuries/Illnesses & Exposure" included in RMS/QCS Version 2.36. Resident Engineer’s and their staff are encouraged to prepare themselves in advance of the next software release.
Activity Hazard Analysis
EM-385-1-1 states “that before beginning each work activity involving a type of work presenting hazards not experienced in previous project operations or where a new work crew or sub-contractor is to perform the work, the Contractor(s) performing that work activity shall prepare an "Hazard Analysis" Since the activity is clearly a contractor required activity QCS 2.36 will include a "Hazard Analysis Contractor Library" and a Contract Specific Hazard Analysis module.
EM-385-1-1 (Figure 1-2 Activity Hazard Analysis) requires contractors to define activities being performed and the sequences of work, the specific hazards anticipated, site conditions, equipment, materials, and the control measures to be implemented to eliminate or reduce each hazard to an acceptable level of risk. In the July 2005 Article of the Month "Contractor Pre-Planning for the Preparatory Phase" Bob Smith pointed out that “a pre-planning safety meeting with the trade personnel will help focus the safety requirements for the project so that a successful approach to the safety issues can be achieved.” Bob points out the Preparatory Inspections are the place to prepare subcontractors to safely plan and start work.
Activity Hazard Analysis (AHA) is conducted for each feature of work. Using the Hazard Analysis Library in QCS Contractor’s can identify each of the following items:
Principal Steps
Potential Safety/Health Hazards
Recommended Controls
Equipment to be used
Inspections
Hazard Analysis – Inspection Requirements
Training Requirements
Hazard Analysis – Training Requirements
As the contractor advances his library the next task is to prepare a project specific AHA for each feature of work and tailored for the subcontractor or crew performing the work. A common mistake made by all contractors is failing to allow adequate time for preparation and review of the Activity Hazard Analysis. Each AHA requires Government Approval therefore it must be completed well in advance of the planned Preparatory Inspection Conference.
Once complete the contractors’ safety engineer certifies the AHA and annotates by checking the “Hazard Analysis Completed” box in QCS.” This check indicates the AHA is ready for electronic submittal to the Government. Upon receipt the Resident Office staff has the following options in RMS:
Government Options (RMS “radio buttons”)
In Review
Hazard Analysis Accepted
Not Accepted. Return to Contractor for corrections
Government review frequently requires coordination with the District Safety Office. Since the Contractor’s AHA is maintained in RMS the task of primary and secondary reviews is easily automated by training all employees how to use RMS.
Hazard Analysis Acceptance is accomplished by checking the “accepted” radio button in the Hazard Analysis module. Government remarks to the contractor are entered into a text box. All remarks and acceptance status will be returned to the contractor electronically.
Hazard Analysis Not Accepted is accomplished by using the “not accepted radio button” and completing the Government Remarks to Contractor memo field to annotate the reasons for disapproval.
Safety Exposure and Accident Reporting
In the June 2005 Article of the Month "Contractor Accident Reporting and Record Keeping" the revised accident reporting and recording keeping requirements were reviewed. RMS/QCS Version 2.36 have automated the record keeping for both Contractors and the Resident Engineer.
Safety exposure and accident reporting are contract requirements, both are required to be maintained and transmitted from QCS. Each daily QC report will require the CQC and Contractor Safety Engineer to record the following:
Prime/Sub Exposure Hours to Date Exposure Hours for the Year Exposure Hours for the Month
Once the CQC annotates the daily report as complete the safety exposure data is electronically submitted to the Corps via the QCS to RMS export data exchange.
Upon receipt the Resident Engineer staff has the following options:
Government Options
In Review
Hours Accepted
Hours not accepted. Return to Contractor for corrections.
The review and acceptance process is similar other modules in RMS. Simply annotate the appropriate “radio button” and add comments in the text field describing any remarks or reasons for not accepting the data.
Accident Reporting is tracked by the CQC and Safety Engineer in QCS. In event of an accident the Prime Contractor shall immediately record the following in QCS:
Accident Reporting
Labor Classification
Prime/Sub
Age
Gender
Where event occurred
Describe the injury or illness
Death
Days away from work
Job transfer or restriction
Other recordable cases
On job transfer or restriction
Days away from work
Injury
Skin disorder
Respiratory Conditions
Poisoning
Hearing loss
All other illnesses
Data is again transmitted electronically to the Resident Engineer via the QCS to RMS export data exchange. The Resident Engineer shall immediately review the data and contact the District Safety Office advising of the incident and receipt of the data. The District Safety Officer can easily review all data from RMS and provide immediate feedback to the Resident Engineer.
The USACE Prime Contractor Monthly Record of Work-Related Injuries/Illnesses & Exposure report is continually updated by the QCS to RMS export data exchange. At the end of each month a summary report is transmitted from RMS to the USACE Safety and Occupation Health Office Accident Experience and Analysis System (AEAS).
The importance of Safety Awareness by both Contractor and Corps personnel is just the beginning for successful project execution. The use of the Three Phase Inspection System and Activity Hazard Analysis planning and control will make all of our projects safe.
I encourage readers to become familiar with RMS/QCS 2.36 and improve our overall safety awareness and performance.
1. Safety Awareness: It’s Not Just for Contractors – NSPE PE, March, 2006